The Innovative Payments Association (IPA) recently submitted a comment letter to the Federal Reserve in response to its Request for Information on the future of the Federal Reserve Banks’ check services. As policymakers consider how the payments system should evolve, the IPA emphasized the importance of prioritizing secure, efficient electronic payment options over continued reliance on paper checks.

In the letter, the IPA notes that electronic payment methods, including prepaid accounts, mobile wallets, and other digital payment products, offer stronger consumer protections and greater efficiency than traditional paper checks. These products are typically governed by federal consumer protection rules, provide error resolution and limited liability protections, and operate within regulated banking and anti-money laundering frameworks.

The IPA also highlighted the role electronic payments play in expanding financial access. Government agencies increasingly use digital and prepaid payment options to distribute benefits such as Social Security, unemployment insurance, and tax refunds. These tools help reach unbanked and underbanked consumers while reducing administrative costs and fraud risks associated with mailed checks.

​As the Federal Reserve evaluates the future of its check services, the IPA urged the Board to carefully consider the benefits of modern electronic payment systems and to conduct a transparent review of how payment infrastructure should evolve.

The Innovative Payments Association (IPA) recently submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in response to its request for input on Reg E requirements for prepaid accounts. The letter reflects IPA members’ view that the current Prepaid Rule has not kept pace with how consumers use prepaid products and mobile financial tools today.

Prepaid accounts, including prepaid cards, mobile wallets, and peer-to-peer payment products, have become primary financial tools for millions of Americans. However, key aspects of the rule were developed before widespread mobile banking adoption and now impose compliance obligations that are often duplicative, outdated, and confusing for both providers and consumers.

In its comments, the IPA outlines targeted recommendations to modernize the regulation while maintaining strong consumer protections. These include streamlining disclosure requirements, revisiting rigid electronic disclosure formatting standards, and aligning prepaid account obligations more closely with those that apply to credit cards and traditional deposit accounts.

The IPA believes thoughtful modernization of the Prepaid Rule would reduce unnecessary regulatory burden, support innovation, and better reflect how consumers interact with financial services today -- without weakening Reg E’s core protections.

For a detailed discussion of IPA’s recommendations and policy rationale, download the full comment letter.

The Innovative Payments Association (IPA) recently submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in response to its Request for Information (RFI) on community banks’ engagement with core processors and other essential third-party service providers. The RFI seeks insight into how these relationships function, the challenges community banks face, and whether additional supervisory or regulatory action may be warranted.
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In its letter, IPA emphasized the critical role bank-fintech partnerships play in enabling community banks to compete in an increasingly digital and online marketplace. These arrangements allow community banks to offer modern, technology-driven financial products while maintaining safety, soundness, and strong consumer protections. IPA highlighted that many of its members operate within these partnerships, either as sponsoring financial institutions or as fintech service providers, and have seen firsthand the benefits these models deliver to banks and consumers alike.

IPA also underscored the importance of bank-fintech partnerships in expanding financial inclusion. Products such as prepaid and fintech debit accounts, earned wage access, and buy-now-pay-later solutions have helped underserved and underbanked consumers access the financial mainstream. These offerings reduce reliance on more costly alternatives and provide users with fraud protections, budgeting tools, and real-time account access comparable to traditional banking services.

Beyond consumer benefits, IPA noted that bank-fintech partnerships have been instrumental in supporting government payment programs at the federal, state, and local levels. These partnerships have enabled faster, more cost-effective electronic disbursement of government funds, particularly for recipients without traditional bank accounts, and played a significant role during the COVID-19 pandemic response.

Importantly, IPA stressed that bank-fintech arrangements already operate within a robust and well-established regulatory framework. Existing interagency guidance, banking laws, consumer protection rules, and supervisory tools provide regulators with meaningful oversight and risk management capabilities. While acknowledging that enforcement actions have occurred in cases of inadequate oversight, IPA cautioned against imposing additional or overly prescriptive regulations that could increase costs, stifle innovation, and ultimately disadvantage community banks and consumers.

IPA encouraged the OCC to carefully weigh both the benefits of these partnerships and the sufficiency of the current regulatory framework before pursuing new regulatory requirements.

The Innovative Payments Association (IPA) has submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to its Advanced Notice of Proposed Rulemaking (ANPR) on Personal Financial Data Rights under Section 1033 of the Dodd-Frank Act.

The CFPB’s ANPR, published August 22, 2025, reopens several elements of the agency’s 2024 final rule, including how to define a “representative,” how to manage costs associated with data sharing, and how to address privacy and security concerns. The IPA’s letter, filed October 10, 2025, provides feedback on each of these areas on behalf of its members, who represent the broad electronic payments industry—from prepaid products to mobile wallets and person-to-person payment technologies.

Clear Consent and Consumer Control

IPA supports the idea that consumers should control access to their financial data and that any third-party representative should obtain clear, informed consent. The letter recommends that consent be explicit and affirmative—an “opt-in,” not hidden in lengthy terms and conditions.

However, the association cautions that limiting representatives only to those with fiduciary duties could slow innovation and reduce consumer choice. IPA encourages the CFPB to maintain flexibility that allows new types of financial technology providers to participate responsibly in open banking.

Cost, Security, and Privacy Considerations

The IPA urges the CFPB to engage directly with stakeholders to develop a fair framework for sharing the costs of data access. It points to the recent Plaid–JPMorgan Chase agreement as an example of how private-sector collaboration can advance responsible data-sharing practices. The association supports allowing reasonable fees to help data providers maintain secure systems.

IPA also recommends creating a safe harbor from liability for financial institutions and data providers that comply in good faith. This would help mitigate risks related to fraud or unauthorized access to sensitive data.

Regarding privacy, the IPA notes that some federal requirements may overlap or even conflict with state laws, such as the California Consumer Privacy Act. It encourages the CFPB to provide clear guidance to help providers navigate these evolving frameworks.

Collaboration and Implementation

Finally, the IPA recommends that the CFPB engage industry representatives through joint discussions rather than litigation and allow additional time, up to two years after technical standards are finalized, for implementation of any new rule.

IPA appreciates the CFPB’s willingness to revisit these important issues and remains committed to supporting policies that foster innovation, protect consumers, and strengthen confidence in the payments system

For additional information, download the comment letter.

The Innovative Payments Association (IPA) submitted a formal comment in response to the June 20, 2025, Request for Information (RFI) from the prudential banking regulators (the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Federal Reserve Board) regarding potential actions to address payments fraud, with a focus on paper checks.

Our Point of View

• Prioritize collaboration and education over new rules. Financial institutions already operate under a robust framework governing check processing and fraud resolution. We believe the most effective next steps are stronger public-private collaboration, improved data sharing, and expanded consumer and business education about the risks of check fraud.
• Convene stakeholders to accelerate solutions. We encourage the prudential regulators to host joint meetings with industry participants to coordinate practical anti-fraud measures, citing existing models of public-private cooperation that can be adapted to the check-fraud context. Targeted law-enforcement task forces focused on check fraud could further deter criminal activity.
• Support the transition to safer electronic payments. The most durable way to reduce check fraud is to continue shifting away from paper checks to secure, fully regulated electronic options, including direct deposit to DDAs, mobile wallets, prepaid accounts, and other digital rails governed by Regulation E. This transition is already underway as check usage declines and electronic methods grow.
• Advance inclusion and program efficiency. Electronic disbursements are central to how many public programs deliver benefits today, providing recipients with faster, safer access to funds and an on-ramp to broader financial services. Continued modernization will enhance outcomes for both consumers and administrators.
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We appreciate the agencies' focus on mitigating fraud while supporting an inclusive and efficient payments ecosystem. For details, you can read our filed comment letter.
If members have questions about the filing, please contact Brian Tate at [email protected].